Haleigh McBride v. Estis Well Service L. L., 731 F.3d 505

Accident on Estis Rig 23 (a barge-mounted drilling rig) in Bayou Sorrell: derrick pipe shifted while crew straightened a twisted monkey board, causing rig to topple; one crew member killed and three injured.
Plaintiffs (decedent’s estate and injured crew) sued Estis for unseaworthiness under general maritime law and for Jones Act negligence; they sought compensatory and punitive damages.
Magistrate Judge granted defendant’s motion to dismiss punitive-damages claims; district court certified interlocutory appeal under 28 U.S.C. §1292(b).
Central legal question: whether punitive damages are available to seamen for unseaworthiness under general maritime law despite statutory maritime remedies (Jones Act/DOHSA) that limit certain damages.
Fifth Circuit reviews de novo and grounds its analysis on Supreme Court precedent (Miles and Atlantic Sounding/Townsend) concerning whether statutory maritime law displaces common-law maritime remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are punitive damages available under general maritime law for unseaworthiness?	Punitive damages remain available: unseaworthiness and punitive remedies predated the Jones Act and Jones Act did not displace them.	Punitive damages are barred because plaintiffs seek relief for harms (death/injury) also covered by statutory maritime law, which limits non-pecuniary remedies.	Reversed: punitive damages are available for unseaworthiness when historically established pre-Jones Act and not displaced by statute.

Atlantic Sounding Co. v. Townsend, 557 U.S. 404 (2009) (supreme court restored punitive damages for maintenance and cure and limited Miles’ reach)
Miles v. Apex Marine Corp., 498 U.S. 19 (1990) (held nonpecuniary loss-of-society damages unavailable in wrongful-death maritime actions due to statutory limits)
Guevara v. Maritime Overseas Corp., 59 F.3d 1496 (5th Cir. 1995) (en banc) (held punitive damages unavailable for maintenance and cure; later abrogated by Townsend)
Complaint of Merry Shipping, Inc., 650 F.2d 622 (5th Cir. 1981) (recognized punitive damages for unseaworthiness upon willful and wanton misconduct)
Moragne v. States Marine Lines, Inc., 398 U.S. 375 (1970) (recognized a wrongful-death remedy under general maritime law)
Vaughan v. Atkinson, 369 U.S. 527 (1962) (permitted attorneys’ fees as punitive sanction for willful refusal to pay maintenance and cure)
The Amiable Nancy, 16 U.S. (3 Wheat.) 546 (1818) (early recognition of punitive-like maritime sanctions)